La
Forest
J.
(orally):
It
will
not
be
necessary
to
hear
from
you
Ms.
Burns.
The
Court
is
ready
to
give
judgment
and
I
will
ask
Mr.
Justice
lacobucci
to
deliver
the
judgment
of
the
Court.
Iacobucci
J.
(orally;
Laforest,
L’Heureux-Dubé,
Gonthier,
Cory,
We
are
all
of
the
view
of
that
this
appeal
should
be
dismissed
for
the
reasons
of
Marceau
J.A.
in
the
Federal
Court
of
Appeal.
We
would
add
that
in
our
opinion
the
provisions
of
the
Canada-Germany
Tax
Agreement
do
not
apply
in
these
circumstances
to
prevent
the
operation
of
section
180.2
of
the
Income
Tax
Act.
Accordingly,
the
appeal
is
dismissed
with
costs.
Appeal
dismissed.
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